Consumer Health Data Privacy Policy

Last updated: July 25, 2026

Swolly is operated by Swolly LLC. In this policy, "consumer health data" means personal information linked to you that identifies your past, present, or future physical or mental health status.

1. Categories of consumer health data we collect, and why

Category	Why we collect it
Bodily measurements — height, weight, age, gender, and weight change over time	To calculate the calorie and macronutrient targets you asked us to personalize, and to score weight-based competitions you choose to join
Fitness activity — steps, distance, calories burned, active minutes, and workout records	To display your activity, and to score competitions you choose to join
Nutrition data — food and calorie logs, macronutrients, dietary preferences and restrictions, meal plans, and saved recipes	To operate the food logging, meal planning, and nutrition tracking features you use
Precise location — GPS coordinates recorded during a run you start	To map and measure that run. Recorded only while a run is active, and only if you grant location permission
Health-related messages you write — questions and content you send to the in-app AI companion, and health-related text in posts or comments	To generate a response, and to display content you chose to post
Inferences — calorie and macronutrient targets and fitness suggestions derived from the above	To personalize targets and suggestions in the app

We collect consumer health data only as necessary to provide features you request, or with your consent. We do not use it for advertising, and we do not use it to build profiles for any purpose other than operating the features described above.

2. Sources of consumer health data

• You. Information you enter directly — profile details, food logs, workouts, posts, comments, and AI messages.
• Your device's health app, with your permission. Apple Health (iOS) or Health Connect (Android). Swolly only reads this data, only the categories listed in the app under More → Health Connections, and only after you grant permission. You can revoke it at any time in your device settings or by disconnecting in Swolly.
• Your device's location services, with your permission, while a run is actively being recorded.
• Derived from the above by our own calculations (for example, a daily calorie target).

3. Categories of consumer health data we share

We do not sell consumer health data, and we have never sold it. Selling consumer health data would require your separate written authorization, which we do not seek because we do not sell it.

We do not share consumer health data with third parties for their own purposes. The only disclosures we make are to processors — service providers who handle data solely on our behalf, under contract, and who may not use it for their own purposes:

Processor	What it handles
Google LLC (Firebase)	Hosts our database, file storage, authentication, and server functions. All consumer health data described above is stored on Firebase servers in the United States.
Google LLC (Gemini API)	Generates responses in the AI companion. Only the message you send and the context needed to answer it are transmitted.
RevenueCat, Inc.	Processes Swolly Pro subscriptions. Receives subscription and purchase data only — no consumer health data.

What other Swolly users can see

If you join a competition, other participants in that competition see your display name, profile photo, your score and rank, and any posts, comments, or chat messages you choose to write there. They do not see your underlying health data, your food logs, your body measurements, or your GPS routes. You are shown a disclosure describing this before you join a competition that uses health-sourced data.

4. How to exercise your rights

If you are a Washington or Nevada resident, you have the right to:

• Confirm and access the consumer health data we hold about you
• Obtain a list of all third parties and affiliates with whom we have shared your consumer health data
• Withdraw consent to our collection and sharing of your consumer health data
• Delete your consumer health data
• Appeal a refusal to act on any of the above

In the app

• Access: More → Privacy & Data → Download my data. We email you a copy of your account data.
• Delete: More → Privacy & Data → Delete my account. See our deletion page for exactly what is removed and how to request deletion by email instead.
• Withdraw consent to health data collection: More → Health Connections → disconnect, or revoke permission in your device settings. Swolly stops reading immediately.
• Withdraw consent to analytics: More → Privacy & Data. Analytics, crash reporting, and performance monitoring are off by default and only run if you turn them on.

By email

Email support@swolly.io with the subject "Consumer Health Data Request", from the address on your Swolly account. We will verify the request comes from you and respond within 45 days, and may extend once by a further 45 days where reasonably necessary, in which case we will tell you why within the first 45 days.

Appeals

If we decline your request, we will tell you why and how to appeal. To appeal, reply to our response or email support@swolly.io with the subject "Consumer Health Data Appeal". We will respond within 45 days. If we deny your appeal, you may complain to the Washington State Attorney General or, in Nevada, the Nevada Attorney General.

5. Retention

We keep consumer health data for as long as your account is active. When you delete your account, it is deleted as described on our deletion page, and we instruct our processors to do the same. Accounts inactive for 24 months may be deleted after an emailed warning and a 30-day grace period.